Service permanent establishment requires non-auxiliary services, while arm's-length distributor remuneration precludes further profit attribution in I...
Make-available condition excludes standard SaaS subscription receipts where customers receive no independently usable technical knowledge after subscr...
Anonymous donation classification fails where charitable trusts maintain undisputed donor identity records and evidence corpus contributions' intended...
Transfer pricing method selection favours TNMM where medical-equipment distribution involves substantial post-import value addition and operational ri...
Substitution of attached proceeds of crime with a bank guarantee does not justify release of identifiable immovable property under the PMLA. The statutory scheme aims to prevent enjoyment of assets derived from illegal activity and preserve them for confiscation or restitution. Releasing such property for use or transfer may enable its depletion, generate further funds, and legitimise income derived from it, undermining those objectives. The request for de-attachment and substitution with an equivalent bank guarantee was rejected, and the writ petition was dismissed.
Substitution of attached proceeds of crime with a bank guarantee does not justify release of identifiable immovable property under the PMLA. The statutory scheme aims to prevent enjoyment of assets derived from illegal activity and preserve them for confiscation or restitution. Releasing such property for use or transfer may enable its depletion, generate further funds, and legitimise income derived from it, undermining those objectives. The request for de-attachment and substitution with an equivalent bank guarantee was rejected, and the writ petition was dismissed.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4817 
Join Channel 
